WA Money Transmitter/MT New Application Checklist (Company) - NMLS
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WA Money Transmitter/MT
New Application Checklist (Company)
CHECKLIST SECTIONS
General Information
License Fees
Requirements Completed in NMLS
Requirements/Documents Uploaded in NMLS
Requirements Submitted Outside of NMLS
GENERAL INFORMATION
Washington Department of Financial Institutions participates in the Multistate Money Services Businesses
Licensing Agreement Program (MMLA), which creates a more efficient money service business licensing process
among state regulators. If your company is seeking money transmitter licensure in more than five (5) states,
participation in the MMLA may be right for you. See the Multistate MSB Licensing Agreement Program page of
the NMLS Resource Center for more information.
Who Is Required To Have This License? A company needs this license if they:
Receive money or its equivalent value (equivalent value includes virtual currency) to transmit, deliver, or instruct
to be delivered to another location, inside or outside the United States, by any means including but not limited
to by wire, facsimile, or electronic transfer.
Sell, issue, or act as an intermediary for open loop prepaid access and payment instruments.
*Money transmission does not include: The provision solely of connection services to the internet, telecommunications
services, or network access; units of value that are issued in affinity or rewards programs that cannot be redeemed for
either money or virtual currencies; and units of value that are used solely within online gaming platforms that have no
market or application outside of the gaming platform
See RCW 19.230.010 (18).
Activities Authorized Under This License
This license authorizes the following activities…
o Electronic money transmitting
o Issuing or selling of traveler’s checks
o Issuing or selling of money orders
o Bill paying
o Issuing and/or selling drafts
o Transporting Currency
o Issuing prepaid access/stored value
o Selling prepaid access/stored value
o Foreign currency dealing or exchanging
Updated: 10/21/2021 Page 1 of 13o Other – money services
Pre-Requisites for License Applications
Tangible Net Worth – At least $10,000 for every one million dollars of money transmission and payment
instrument dollar volume. The minimum tangible net worth is $10,000; the maximum is $3,000,000. Virtual
Currency/Cryptocurrency MT companies who will be holding wallets on behalf of their clients will need to
maintain a minimum tangible net worth of $100,000; the maximum is $3,000,000.
See WAC 208-690-060
Surety Bond amount - Each money transmitter licensee shall maintain a surety bond in an amount based on the
previous year's money transmission dollar volume; and the previous year's payment instrument dollar volume.
The minimum surety bond must be at least $10,000, and not to exceed $550,000. The director may adopt rules
to implement this section.
Register as a Money Services Business (MSB) with the US Treasury Department – MSBs must register with the
United States Treasury Department. Information regarding MSB responsibilities under federal law can be
obtained at Money Services Business (MSB) Registration | FinCEN.gov or request a package of
information by phoning 1-800-949-2732
Business License – The Company must obtain a Business License issued by the Washington State Department of
Revenue, Business Licensing Service (BLS) at 1-800-451-7985 or http://bls.dor.wa.gov . The company must
register trade names (“DBA”) on their Business License as well. The company will find their Unified Business
Identifier (UBI) number on the Business License.
Washington Secretary of State – If the company is not a sole proprietorship, it must register the company with
the Washington Office of the Secretary of State http://www.secstate.wa.gov.
Department of Revenue – Go to the Washington DOR website, https://dor.wa.gov/doing-business/register-
my-business, to see if the business is required to be registered with them. If the company meets the
requirements listed then they must register before applying for the license.
WA DFI does not issue paper licenses for this license type. The company will receive a copy of the license via
email.
Document Uploads Guidance
Documents that must be uploaded to the Document Uploads section of the Company Form (MU1) in NMLS are
indicated in the checklist below. When uploading documents:
Follow the guidance in Document Upload Descriptions and Examples.
Only upload documents relevant to the company application.
Only upload documents where there is a selectable document category. If inappropriate documents are
uploaded the company will be contacted by the regulator and asked to remove them from NMLS.
Do not upload the same company documents multiple times. Unless the document is state-specific or the
document has already been uploaded for another state, a new upload is not required unless changes have been
made.
If a document previously uploaded has been revised, delete the old document and replace it with the new
document (history of the old document will remain in NMLS).
For state-specific documents (e.g. Surety Bonds), be sure to indicate the applicable state.
Helpful Resources
Company Form (MU1) Filing Instructions
Document Upload Descriptions and Examples
Updated: 10/21/2021 Page 2 of 13 Individual Form (MU2) Filing Quick Guide
Financial Statements Quick Guide
Payment Options Quick Guide
License Status Definitions Quick Guide
Agency Contact Information
Contact Consumer Services licensing staff by phone at 360-902-8703 or send your questions via email to
CSLicensing@dfi.wa.gov for additional assistance.
THE APPLICANT/LICENSEE IS FULLY RESPONSIBLE FOR ALL OF THE REQUIREMENTS OF THE LICENSE FOR WHICH THEY ARE APPLYING.
THE AGENCY SPECIFIC REQUIREMENTS CONTAINED HEREIN ARE FOR GUIDANCE ONLY TO FACILITATE APPLICATION THROUGH NMLS.
SHOULD YOU HAVE QUESTIONS, PLEASE CONSULT LEGAL COUNSEL.
Updated: 10/21/2021 Page 3 of 13LICENSE FEES - Fees collected through NMLS are NOT REFUNDABLE OR TRANSFERABLE.
Complete WA Money Transmitter Submitted via…
WA Application Fee: $1,000.00 NMLS (Filing
submission)
See WAC 208-690-130
NMLS Initial Processing Fee: $100
Credit Report for Control Persons: $15 per control person. NMLS (Filing
submission)
Criminal Background Check: $36.25 per person NMLS (Filing
submission)
Uniform Authorized Agent Reporting Annual Processing Fee: An annual fee of NMLS (Agency Fee
twenty-five cents ($0.25) for each active authorized agent/delegate location Invoice)
reported through NMLS is invoiced on November 1st.
There is no fee for the first 100 active agents reported (Companies with 100
agents or less are not subject to the UAAR Processing Fee).
The fee is capped at $25,000 per licensee in any one year.
The invoiced amount is based on the number of active agents in the system as
of August 16th, (day after third quarter reporting deadline).
See the Uniform Authorized Agent Reporting Processing Fee Fact Sheet for
more information.
Addition of Authorized Agents reported at time of licensing: A fee of $100.00 NMLS (Agency Fee
will be charged for each additional location where the company or an Invoice)
authorized agent will provide money services, up to a maximum of five
thousand dollars per quarter.
REQUIREMENTS COMPLETED IN NMLS
Complete WA Money Transmitter Submitted via…
Submission of Company Form (MU1): Complete and submit the Company NMLS
Form (MU1) in NMLS. This form serves as the application for the
license/registration through NMLS.
Financial Statements: Upload the most recent Audited financial statements, NMLS
include a balance sheet, income statement, and statement of cash flows and all
Upload under Financial
Updated: 10/21/2021 Page 4 of 13relevant notes there to prepared by a Certified Public Accountant in accordance Statement Summary in
with Generally Accepted Accounting Principles. The most recent interim the company MU1 form
financial statements are also required and must be prepared in conformity with
US GAAP. These interim financial statements may be audited or unaudited.
The unaudited reports are required to be signed by the company’s chief
financial officer or executive.
New Business applicants with limited or no business operations prior to
application must submit a copy of financial statements for the new business
whether audited or not. Additionally, where applicable, the audited financial
statements or annual reports of the parent company are required.
Required financial documentation needed:
Current financial statements as of the most recent quarter end for the
business.
Most recent financial statements for the past 2 years. Audited if
available or unaudited if newly formed business.
If a newly formed business, also upload documentation supporting the
company’s method and source of capitalization (where the funding for
the business comes from).
If the company is a wholly-owned subsidiary of another corporation, it
may upload either the parent’s consolidated audited financial
statements of the current year and prior two years, or the parent’s
Form 10K reports filed with the United States Securities & Exchange
Commission for the prior three years in lieu of the financial statements.
Two-year projected financial statements including projected
transmission volumes for the business - upload these under Additional
Requirements in the Document Uploads section of the company MU1.
See WAC 208-690-080
Note: Financial statements are uploaded separately under the Filing tab and
Financial Statement submenu link. See the Financial Statements Quick Guide
for instructions.
Authorized Agents (Delegates) Locations: NMLS
Licensees must use the NMLS Uniform Authorized Agent Reporting (UAAR)
functionality to report Authorized Agents. Upon license approval, applicants
are required to utilize the UAAR to upload a list of agents who are authorized to
conduct money transmission business in the state of Washington on the
Applicant’s behalf. Agent adjustments (additions, deletions, and modifications)
must be submitted through the UAAR within thirty days of the occurrence of
the change. The company must also file the report even if there are no changes
to report. For more information, consult the NMLS Resource Center.
If the company will be using authorized delegates they must also upload the
following documents under “Document Samples” in the Document Upload
section of the MU1.
Sample contract for independent authorized delegates
A full description of the screening process used by the applicant in
selecting authorized delegates, including any forms used, and the
Updated: 10/21/2021 Page 5 of 13method used to screen for criminal history
Other Trade Name: NMLS
If operating under a name that is different from the applicant’s legal name, that
name (“Trade Name”, “Assumed Name” or “DBA”) must be listed under the
Other Trade Names section of the Company Form (MU1). Washington DFI does
not limit the number of other trade names.
Resident/Registered Agent: Not required for Money Transmitter companies NMLS
whose main office location is in Washington. If the main office location is out of
state, the Resident/Registered Agent must be listed under the
Resident/Registered Agent section of the Company Form (MU1) and must
match the information currently on record with Washington Secretary of State.
Primary Contact Employees: The following individuals must be entered into NMLS
the Contact Employees section of the Company Form (MU1).
1. Primary Company Contact.
2. Primary Consumer Complaint Contact.
Approvals and Designation: Enter the company MSB registration number on NMLS
the FinCEN Registration line (list confirmation # and filing date). Enter the
company’s Unified Business License number (UBI number) on the “Other
Approval/Designation” line.
Bank Account: NMLS
Identify the account that is used for the money transmission activities. The
account must be in the name of the applicant
For third Party Account Administrators, the account must be a dedicated bank
account at an insured financial institution for fees and payments to creditors,
debt collectors, debt adjusters, or debt adjusting agencies in connection with
the renegotiation, settlement, reduction, or other alteration of the terms of
payment or other terms of a debt.
Disclosure Questions: Provide a complete and detailed explanation and NMLS
document upload for each “Yes” response to Disclosure Questions made by the
Upload in the Disclosure
company or related control persons (MU2). (e.g. if the company has two
Explanations section of
orders/agreements they entered into with other states, the company must
report two separate explanations and attach the legal documentation for each
the Company Form
(MU1) or Individual
order/agreement under the appropriate explanation)
Form (MU2).
See the Company Disclosure Explanations Quick Guide for instructions.
Qualifying Individual: Enter the Responsible Individual (RI) in the Qualifying NMLS
Individual section. This is the individual who is employed by the licensee and
Upload under Legal
has principal managerial authority over the provision of money services by the
licensee in this state. The Responsible Individual must:
Name/Status
Documentation in the
Be a citizen of the United States or have legal immigration status Document Upload
to work in the United States; section.
Updated: 10/21/2021 Page 6 of 13 Hold W-2 employee status with the licensee;
Be knowledgeable of the laws and rules implementing the act;
and
Be responsible for the company's compliance with applicable
state and federal laws, rules and regulations.
If the RI is not a US Citizen, upload documentation of the person’s right to work
in the US. Examples:
Employment Authorization Document
Permanent Resident Card
Visas of type H-1B, L-1B or P
Control Person (MU2) Attestation: Complete the Individual Form (MU2) in NMLS
NMLS. This form must be attested to by the applicable control person before it
is able to be submitted along with the Company Form (MU1).
Credit Report: Individuals in a position of control are required to authorize a NMLS
credit report through NMLS. Individuals will be required to complete an
Identity Verification Process (IDV) along with an individual attestation before a
license request for the company can be filed through NMLS. This authorization
is made when the Individual Form (MU2) is submitted as part of the Company
Form (MU1). Click here for instructions
Criminal Background Check (Fingerprints): Individuals in a position of control NMLS
are required to authorize a criminal background check (submit fingerprint)
through NMLS. Click here for instructions
REQUIREMENTS/DOCUMENTS UPLOADED IN NMLS
Complete WA. Money Transmitter Submitted via…
AML/BSA Policy: Upload an Anti-Money Laundering (AML) / Bank Secrecy Act NMLS
(BSA) Policy. Include an independent review if available.
Upload under the
This document should be named (company name – AML Policy Internally Document Type
Approved Date mm-dd-yyyy). AML/BSA Policy in the
The AML/BSA Policy must have a company risk assessment included or
Document Uploads
section of the Company
as a stand-alone document. The risk assessment should evaluate all risk
Form (MU1).
areas of the company, and provide a rating of each risk as well as
mitigating steps taken to reduce that risk.
Updated: 10/21/2021 Page 7 of 13Business Plan: Upload a business plan outlining the following information: NMLS
Executive summary of the business Upload under the
Document Type Business
Products/Services intended to be offered under the license
Plan in the Document
Target markets and marketing strategies, including fee schedule Uploads section of the
Company Form (MU1).
Management and organization of the business
Operational plan, including flowchart of a typical transaction
Assessment Tracking: Provide the company’s method for tracking
Washington business separately from business conducted in other
states. This is for the purpose of annual reporting and calculating surety
requirements.
This document should be named [Company Legal Name] Business Plan.
Note: If the existing uploaded business plan already includes the above
information, an additional document does not need to be uploaded. A company
should only upload a single business plan. If state-specific material is required,
this information should be added to the existing uploaded business plan.
Third Party Account Administrators only: TPAAs may not be owned or NMLS
controlled by, or in any way affiliated with, a debt adjuster. If the company is a
Upload under Debt
TPAA, an authorized official of the company must sign the declaration below:
Management
Agreement in the
Document Uploads
I declare that the applicant is not owned, controlled by, or in any way affiliated
section of the Company
with, a debt adjuster.
Form (MU1).
Signature:
Printed Name:
Title:
Date:
Document Samples: Upload copies of the following sample documents used in NMLS
the regular course of business in connection with this license:
Upload under Document
Money transmission receipts Samples in the
Document Uploads
If applicable: section of the Company
Form (MU1).
Sample contract for independent authorized delegates
A full description of the screening process used by the applicant in
selecting authorized delegates, including any forms used, and the
method used to screen for criminal history
Updated: 10/21/2021 Page 8 of 13Flow of Funds Structure: Submit a description of each type of transaction or NMLS
service to be conducted. For each type, describe each step starting with the
Upload under Flow of
first encounter with the consumer and ending at the completion of the
Funds Structure in the
transaction when money is received by the beneficiary.
Document Uploads
This document should be named Flow of Funds Structure. section of the Company
Form (MU1).
Note: If submitting multiple types of transactions or services to be conducted,
combine in single document for upload.
Management Chart: Submit a Management chart displaying the applicant’s NMLS
organization/divisions, directors, officers, and managers (individual name and
Upload under
title).
Management Chart in
This document should be named [Company Legal Name] Management Chart. the Document Uploads
section of the Company
Note: If the existing uploaded management chart already includes the above
Form (MU1).
information, an additional document does not need to be uploaded. A company
should only upload a single management chart.
Organizational Chart/Description: Submit a chart showing (or a description NMLS
which includes) the percentage of ownership of:
Upload under
Direct Owners: total direct ownership percentage must equate to 100% Organizational
Chart/Description in the
Indirect Owners
Document Uploads
Subsidiaries and Affiliates of the applicant/licensee section of the Company
Form (MU1).
This document should be named [Company Legal Name] Organizational Chart –
Description.
Note: If the existing uploaded Organizational Chart/Description already
includes the above information, an additional document does not need to be
uploaded. A company should only upload a single Organizational chart.
Surety Bond: Submit an Electronic Surety Bond via NMLS in the amount of
$10,000 furnished & submitted by a surety company authorized to conduct
business in Washington. See the ESB for NMLS Licensees page of the NMLS
Recourse Center for more information. Submit Electronically
through NMLS
This document should be named Surety Bond to Operate Money Services
Business
Surety bond must be calculated at ten thousand dollars for every one million
dollars of Washington money transmission and payment instrument dollar
volume. The minimum surety bond is $10,000; the maximum surety bond
amount is $550,000.
Surety Bond Requirements Table
Previous 12-months’ Money Minimum Surety Amount
Transmission and Payment
instrument dollar volume
Zero - $999,999.00 $10,000.00
$1,000,000.00 - $1,999,999.99 $20,000.00
$2,000,000.00 - $2,999,999.99 $30.000.00
Updated: 10/21/2021 Page 9 of 13Continue calculations per volume…
$54,000,000.00 or more $550,000.00
List of Countries: Provide a list of countries the applicant will be transmitting NMLS
money to and from.
Upload under Document
Uploads in the
Additional Requirements
section of the Company
Form (MU1).
12 Month’s Money Transmissions: Provide a written statement with the one- NMLS
line dollar figure that represents the total volume of Washington State money
Upload under Document
transmissions that were transferred over the previous 12 months
Uploads in the
Additional Requirements
section of the Company
Form (MU1).
REQUIREMENTS SUBMITTED OUTSIDE OF NMLS
Complete WA money transmitter Submitted via…
Third Party Investigatory Background Checks: If any control person does not Email Directly to DFI
or has not resided in the US for at least 5 years prior to submission of
Send to your application
application, an investigative background report must be prepared by an
reviewer.
acceptable search firm and submitted directly to the Department in addition to
other background information required in the application. At a minimum, the
report must contain the following:
A comprehensive credit report/history
Civil court and bankruptcy court records for the past 5 years, including
Updated: 10/21/2021 Page 10 of 13a search of the court data in the country(ies), states, towns, where the
individual resided and worked and in contiguous areas
Criminal records for the past 5 years, including felonies, misdemeanors
and violations including a search of the court data in the country(ies),
states, towns, where the individual resided and worked and in
contiguous areas
WASHINGTON LICENSING DECLARATION FORM – MONEY TRANSMITTERS:
NMLS
Each licensee shall establish and maintain a cyber-security program to ensure
the availability and functionality of the licensee's electronic systems and to Upload the Declaration
protect those systems and any sensitive data stored on those systems from Form under Document
unauthorized access, use, or tampering. The program may be established and Uploads in the
maintained by a parent or affiliate as long as the licensee has adopted the Additional Requirements
NOTE section of the Company
program and it is available to the department for review. This information
security plan must be maintained as part of the company’s books and records. Form (MU1).
See WAC 208-690-240 & WA 208-690-250
Contact DFI’s Accessibility Coordinator at accessibility@dfi.wa.gov or (360) 902-0506 to obtain this document in an
alternative format.
Updated: 10/21/2021 Page 11 of 13WASHINGTON LICENSING DECLARATION FORM – MONEY TRANSMITTERS
1. Name of Company:________________ TAX ID# __________________
2. I am above the age of eighteen and am competent to testify to the facts as stated in this declaration.
3. I am authorized to make this Declaration on behalf of the company.
4. I personally reviewed the application submitted on behalf of the applicant in NMLS and all supporting
documents submitted and certify the application and supporting documents do not contain any untrue
statement or omission of any material information or fact.
5. I have read and am familiar with all the Money Transmitters Applicable Laws and Regulations. Among these are:
o Uniform money services Act RCW 19.230
o Unclaimed Property RCW 63.29
o WAC 208-690 - Regulation of Money Services Providers
o 31 CFR Chapter X – Financial Recordkeeping and Reporting of Currency and Foreign Transactions
o Bank Secrecy Act
o FINCEN BSA/AML examination manual for money services businesses
o Gramm-Leach-Bailey Act
o HIDTA - High Intensity Drug Trafficking Area
o HIFCA- High intensity financial crimes area
o IRS: Money services business registration requirements
o Office of Foreign assets control OFAC- Sanctions
o Remittance Transfer rule - Regulation E subpart B
o Virtual currency regulations
6. I affirm the applicant has adopted written policies and procedures concerning:
o Recordkeeping in compliance with WAC 208-690-075
o Business Continuity and Recovery plan (WAC 208-690-280)
o Anti-money Laundering/AML program
o Cyber Security program WAC 208-690-240
7. I understand that all Washington State money transmitters and Online Currency Exchangers are required to:
o Have a surety bond on file. The amount of the bond is determined annually based on the money
transmission and payment instrument dollar volumes conducted in Washington for the previous 12
months.
Updated: 10/21/2021 Page 12 of 138. I understand that all Washington State Money Transmitters and Currency Exchangers are required to:
o File an Annual Assessment Report based on the activities during the reporting year by July 1st.
o Complete an Annual Company License Attestation (renewal) between November 1 and December 31st
each calendar year through NMLS
o Report all company authorized delegates; additions, deletions, and changes through the NMLS system.
Payments for these changes are made through the NMLS system as well.
9. If granted a license, I understand the company will be subject to periodic regulatory examinations and am
familiar with the fees associated with an examination as outlined in WAC 208-690-180. Further if I do business
at a non-United States location I understand and hereby agree to make all records along with a
responsible individual available to the Department at a United States location. I understand that
failure to make records and a responsible individual available in the United States is grounds for
revocation of my license.
10. The applicant will notify the Department of any material change to the information contained in the company’s
record on NMLS and is familiar with reporting requirements in WAC 208-690-110.
11. I understand that any false or fraudulent representation or substantial misrepresentation may be grounds for
denial or revocation of any license granted by the Department.
I DECLARE THAT THE FOREGOING STATEMENTS ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE,
INFORMATION, AND BELIEF. I AM AWARE THAT I AM SUBJECT TO CRIMINAL PROSECUTION UNDER THE
PROVISIONS OF 18 U.S.C 1001
_________________________________ _________________________________ __________________
Compliance Officer – Print Name Signature Date
_________________________________ _________________________________ __________________
Executive Signature Date
Updated: 10/21/2021 Page 13 of 13You can also read
